The US IRS released updates to its frequently asked questions (FAQs) on the FATCA IDES system dated January 5. Under the “general questions” heading, the following FAQs were changed:
Q: How can HCTA and FFI obtain information as to system development progress and status?
A: The IRS publishes this information on the FATCA site on IRS.gov making it universally available at the same time. Additionally, users can subscribe to the FATCA newsletter for updates on the latest IRS news, guidance, regulations and other public information related to FATCA.
Q: What types of technical support will be present during integration testing? How will the HCTAs and FFIs report issues with integration testing back to the IRS?
A: The IDES vendor will provide help desk support under their contract with the IRS during testing as well as when the system goes live. The IRS will provide contact information for the vendor help desk prior to enrollment.
New FAQs to the section titled “data format and structure” are as follows:
Q: When will a template pertaining to the request for information on recalcitrant accounts be provided?
A: A sample Competent Authority Request (CAR) is planned for release as soon as possible on the FATCA page of the IRS.gov web site.
Q: When will sample XML files related to FATCA submissions be available?
A: Sample XML documents for the FATCA NIL reports, sender metadata, and notifications have been uploaded to the IRS.gov website and can be found at FATCA XML Schemas and Business Rules for Form 8966.
Q: What is the format for sending metadata for file transfers to IDES (e.g., indicate a specific sender / receiver)?
A: Procedures for sending metadata files are documented in the IDES User Guide, which can be found at IDES User Guide.
Q: If an individual has only received certain payment types, should the other payment types be listed with a zero amount or should they be omitted from the report for that individual?
A: If an individual has not received a particular payment type, zero amount is acceptable. If a particular payment type is not relevant to the individual, it is preferred that the information be omitted.
Q: What is the procedure for FFIs and HCTAs to verify test data prior to the launch of IDES?
A: IDES is planning to allow enrolled users to upload test files beginning on January 5th, 2015. Specific procedures will be published as soon as possible on IRS.gov.
Q: Can an HCTA create it’s own standard numbering format for the MessageRefID in the 8966 XML Schema for its financial institutions to use?
A: Yes. The only requirement is that the field be be unique for each sender for the lifetime of the system and that it not exceed the maximum length of 200 characters.
Updates to the section titled “data transmission” are as follows:
Q : What are the procedures for sending files to IDES and/or ICMM systems?
A: All files will be submitted through IDES. IDES supports transfers through HTTPS and SFTP. Specific operational procedures for data preparation are documented in the IDES User Guide.
Q: What are the procedures for sending metadata for files to IDES?
A: Metadata files needs to be included in the transmission file submitted to IDES. Specific operational procedures for sending metadata files are documented in the IDES User Guide. Additionally, a sample metadata XML file can be found at FATCA XML Schemas and Business Rules for Form 8966.
Q: Will requests from the IRS for information on recalcitrant accounts be transmitted via email?
A: No, all IRS requests for information will be transmitted via IDES. Format of the message exchange between IRS and HCTA will be published on IRS.gov as soon as reasonable. This only applies to Model 2 jurisdictions.
Q: What is the procedure for sending corrected and/or amended data to receiving HCTA? Will the resubmission need to include only the corrected / amended entries or will the entire report need to be resubmitted?
A: Procedure for submitting corrected or amended data will be the same as the submission of a new report. Specific operational procedures for data preparation are documented in the IDES User Guide. The resubmission should only include the corrected / amended entries, with a reference to the original report. Please refer to the FATCA XML User Guide for preparing corrected or amended reports.
Updates to the section titled “data encryption and security” are as follows:
Q: How will passwords and keys be controlled for data transmission?
A: The public keys for the users will be available through IDES. Each user will have a unique password
Q :Who is responsible for data transmission security via encryption?
A: Each HCTA will initiate a secure transmission to IDES via encrypted session. Likewise, the IRS will initiate a secure transmission to IDES to retrieve data. More information can be found in the IDES User Guide
Q: What are the requirements for digital certificates?
A: IDES currently requires digital certificates from one of seven different certificate authorities. During the FFI and HCTA enrollment process, the digital certificate must be uploaded to the IDES website. A list of acceptable certificate authorities and products can be found at Digital certificates?
Q: Can the AES 256 key be re-used for subsequent data transmissions or does the key have to be different each time?
A: The AES key must always be considered a “one time use” key. Software used to perform AES256 encryption can generate a new AES key for each use.
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